International

  • October 06, 2022

    Norway's $30B Budget Reduces Oil And Gas Exemption

    Following price increases, Norway's government has proposed reducing a temporary income tax exemption for oil and gas companies by around 30% in a budget published Thursday with spending measures worth 316.8 billion kroner ($29.6 billion).

  • October 06, 2022

    OECD Seeks Comments On Tax Deal Progress Report

    The Organization for Economic Cooperation and Development asked for feedback on a progress report released Thursday that contains draft rules and procedures for reallocating corporate tax payments based on where a corporation operates.

  • October 06, 2022

    Fund's Loan Subparticipation Deals VAT-Exempt, ECJ Says

    A securitization fund's so-called subparticipation agreements with banks or investment funds aren't subject to value-added tax because they fall under an exemption for credit services, the European Court of Justice said Thursday.

  • October 05, 2022

    Senate Bill Would Subject Attorneys To Bank Secrecy Rules

    Attorneys involved in providing financial services to third parties would become subject to some Bank Secrecy Act rules under a defense spending bill amendment introduced by bipartisan co-sponsors in the U.S. Senate.

  • October 05, 2022

    UK Man Isn't A Belgium Resident For Taxes, Tribunal Finds

    A U.K. businessman is not a resident of Belgium for tax purposes despite taking steps to change his status, such as living full time in Brussels, a First-tier Tribunal judge ruled.

  • October 05, 2022

    IRS Wants Input On Inflation Reduction Act's Tax Provisions

    The Internal Revenue Service is seeking comments on provisions of the Inflation Reduction Act that deal with clean-energy and other tax credits, according to notices released Wednesday.

  • October 05, 2022

    80% Of US CEOs See Min. Tax As Concern, KPMG Poll Says

    The proposed global minimum tax is a growth concern for the companies of 80% of U.S. CEOs surveyed by advisory firm KPMG LLP, the firm said in a report.

  • October 05, 2022

    Outdoor Maintenance Biz Sues For £7.8M For Post-M&A Woes

    An outdoor maintenance provider has sued the former owners of a parking lot specialist for up to £7.8 million ($8.8 million) after their business ran into problems with a major Tesco contract and significant tax liabilities over the misclassification of subcontractors following the acquisition.

  • October 05, 2022

    Multinationals Drive Growth In Ireland Corp. Tax Revenue

    Profitability among multinationals led to a strong upturn in corporate tax revenue in Ireland over the first nine months of the year, data from the country's finance ministry showed.

  • October 04, 2022

    Canada's Biz Tax Gap Doubles As Profits Surge, Report Says

    Canada's corporate tax gap more than doubled to CA$30 billion ($22.2 billion) last year as price hikes largely produced record profits, an advocacy group said in a report.

  • October 04, 2022

    Wyden Says IRS Funding Boost Should Target Offshore Evasion

    The Internal Revenue Service should use the funding boost passed by Congress under the Inflation Reduction Act to monitor whether offshore entities are properly reporting accounts belonging to U.S. citizens, Senate Finance Committee Chairman Ron Wyden said Tuesday.

  • October 04, 2022

    Sri Lanka Cutting Taxes On Menstrual Pads

    Sri Lanka is cutting taxes on some female hygiene products in a move to ensure their affordability, according to the office of President Ranil Wickremesinghe.

  • October 04, 2022

    Australia Seeks Feedback On OECD Global Tax Plan

    The Australian Treasury is seeking stakeholder insight into the expected challenges of and the best ways to implement the OECD's global tax overhaul, including how to consider a domestic minimum tax, according to a government document published Tuesday. 

  • October 04, 2022

    V&E Loses Ace Tax Atty To Kirkland In Houston

    Kirkland & Ellis LLP has added a partner with a broad range of expertise in tax controversy to its Houston office.

  • October 04, 2022

    Indian Seeks To Dodge Extradition On Prison Violence Fears

    An Indian national facing extradition from the U.K. to India for tax evasion and money laundering offenses would face the risk of "violence and extortion" in prison if extradited, his counsel said at a London court hearing on Tuesday.

  • October 04, 2022

    EU Confirms Blacklisting Of 3 Island Jurisdictions

    The European Union council of member states placed three island jurisdictions on its so-called blacklist of uncooperative jurisdictions for tax purposes Tuesday, confirming a draft document that previewed the decision last week.

  • October 04, 2022

    Ex-F1 Chief To Face 2023 Trial Over Hidden $650M Charges

    Former Formula One racing boss Bernie Ecclestone will face trial next year at a London court over an allegation that he hid more than $650 million in an offshore trust from the British tax authorities.

  • October 03, 2022

    UK Tribunal Says Marshmallows Not Candy For VAT Purposes

    A large type of marshmallow sold in the U.K. to be roasted over a fire is not considered a confectionery for value-added tax purposes, according to a decision by the country's First-tier Tribunal.

  • October 03, 2022

    Ex-Broker Files Counterclaim In $4.6M FBAR Dispute

    A former insurance broker claiming he was wrongly tagged with $4.6 million in penalties for failing to report his foreign bank accounts countersued the U.S., demanding it refund $13,000 to him that it applied toward the debt.

  • October 03, 2022

    UN Urges Gov'ts To Tax Windfalls, Close Loopholes

    Taxing windfall profits and fighting tax avoidance could stem fallout from rich nations' monetary tightening, which is likely to trigger the worst global recession in decades, the United Nations Conference on Trade and Development said Monday in a report.

  • October 03, 2022

    Judge Prods US, Colo. Family To Resolve $2.2M FBAR Case

    A federal judge ordered the U.S. government and members of a Colorado family who allegedly failed to report their foreign bank accounts to wrap up their case involving $2.2 million in penalties and interest by Oct. 31.

  • October 03, 2022

    US Properly Applies FBAR Penalty Per Account, Justices Told

    A lower court correctly interpreted the law in allowing the Internal Revenue Service to impose nonwillful $10,000 penalties for each foreign bank account that a Texas man didn't properly disclose, the U.S. government told the U.S. Supreme Court.

  • October 03, 2022

    IRS Can Seize $1.4B In Property From Dead Software CEO

    A Texas federal judge approved what the IRS calls its largest immediate property seizure in history, a jeopardy collection of $1.4 billion against a deceased software CEO accused of unloading assets as the government closed in on him.

  • October 03, 2022

    Contractor Sues Barrister, Consultants Over Tax Advice

    An infrastructure services provider has sued its tax advisers and a barrister for £12.6 million ($14.1 million) for allegedly wrongly advising it that it was exempt from corporation tax on gains from the sale of its business.

  • October 03, 2022

    Justices To Review Firm's Bid To Shield Client Tax Comms

    The U.S. Supreme Court said Monday it will consider a law firm's bid to shield client communications from grand jury subpoenas seeking documents on its tax advice in a case concerning the scope of attorney-client privilege over mixed-use legal advice.

Featured Stories

  • FATCA Imbalance Raises Questions About Crypto Data Swaps

    Natalie Olivo

    The U.S. government has long lacked the ability to reciprocate the level of information it receives from other countries under the Foreign Account Tax Compliance Act — a dynamic that may complicate domestic and global proposals for cross-border cryptocurrency data exchanges.

  • EU's Stalled Pillar 2 Tax Holds Up Global Adoption

    Todd Buell

    Failure to push the internationally agreed-upon minimum tax known as Pillar Two across the finish line in the European Union — a result of the need for unanimous agreement on EU tax law changes — has hampered the measure's adoption globally.

  • Wyden Probe Shines Light On Private Placement Insurance

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    The top Senate tax writer's investigation into private placement life insurance is bringing scrutiny to a once-obscure estate planning tool for wealthy families that some tax and finance practitioners see as a potentially abusive method for tax evasion.

Expert Analysis

  • Digital Taxation Is Necessary, But Tough To Manage

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    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • Company Considerations For Cash Award Incentives: Part 2

    Excerpt from Practical Guidance
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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

  • Company Considerations For Cash Award Incentives: Part 1

    Excerpt from Practical Guidance
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    Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.

  • What AML Bill Could Mean For Firms, Funds And FinCEN

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    If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.

  • Unpacking The New Stock Buyback Tax And Its Exceptions

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    Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.

  • Inside The OECD Transfer Pricing Documentation Guidance

    Excerpt from Practical Guidance
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    The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.

  • A Close Look At The Decentralized Effort To Tax Digital Assets

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    Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.

  • Key Takeaways From IRS Reversal On FDII Stance

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    The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.

  • New Tax Decree Suggests Expansion In Dutch Transfer Pricing

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    A July 1 decree from Dutch tax authorities updating transfer pricing guidance heralds a major change in how intercompany financial transactions are considered for transfer pricing purposes and forebodes significant audit activity, say Monique van Herksen and Clive Jie-A-Joen at Simmons and Simmons.

  • Is NJ's Voluntary Transfer Pricing Initiative Really Voluntary?

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    The New Jersey Division of Taxation's voluntary transfer pricing audit initiative promises penalty abatement to taxpayers that elect to participate and agree to the division's proposed adjustments, but the effective penalties associated with nonparticipation raise questions about the program's voluntary nature, say attorneys at McDermott.

  • Global Tax Chiefs Should Look To US Whistleblower Programs

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    As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.

  • What Microcaptive Reporting Ruling May Mean For The IRS

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    In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.

  • US Should Leverage Tax Rules To Deter Business With Russia

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    The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.